ICYMI: PSI's Global Best Practices: Packaging EPR's Role in Advancing the Circular Economy - Slides and Recording Available

14 Nov 2018

PSI received many questions from attendees all over the country and globe during the webinar that they were unable to answer  during the live session. Their speakers have kindly replied to the unanswered questions below. 

You can download slides and audio from the live webinar here.
 

1. I think that John was saying that, in the absence of greater harmonization, something like 95% of the value of packaging is lost to the economy.  Could panelists expand on, or give examples of this?
John Coyne (JC): Our view is that harmonized EPR legislation for packaging and paper products will create the economies of scale necessary to help contribute to circular economy outcomes and value creation for plastics. I did not mean to imply that in the absence of greater harmonization, 95% of the value of plastics is lost to the economy. Rather, I was referencing a report released in January 2016 by the World Economic Forum and the Ellen MacArthur Foundation (with analytical support from McKinsey & Company) called The New Plastics Economy - Rethinking the Future of Plastics. It was this report that concluded that globally 95% of the value of plastic is lost to the economy because it is currently disposed in landfill, incinerated or leaks into the environment. Surely we can do better than this, particularly in an era of increasing resource constraints. The work of the Ellen MacArthur Foundation's New Plastics Economy is found here. It is well worth a look.
  
2. Solid waste management services are designed to meet the historical and broad mandates of protecting public health and sanitation across a broad spectrum of products, materials and wastes. How would an optimized EPR system be harmonized and aligned with financing and service delivery across the broader solid waste and public health and sanitation systems?
Joachim Quoden (JQ): I do not see any contradiction here. In Spain they call the system for example "Integrated waste management system" which shows that the separate collection system for packaging, in some countries even for materials, are designed taking into account the previous collection model respective are in agreement with the local authorities if the system is changed / adapted.
 
JC: In most cases the delivery of waste and/or organics collection is provided by the local government and the local government provides that service in a way that best meets their and their residents' needs. In a full producer responsibility jurisdiction, it is possible for a local government, if it elects to contract to a producer responsibility organization (PRO), to align its recycling collection services with its garbage and organics collection.
 
3. When municipalities are partially reimbursed by the stewardship organization for recycling, are there financial incentives for the municipality to reduce contamination in the recycling stream--- i.e. would there be a higher reimbursement for cleaner material?
JQ: This is one of the classical funding mechanisms in many EPR programs in Europe where local authorities are responsible for the collection respective also for waste management companies doing the collection on behalf of the EPR system. You agree a principal price if a certain minimum quality and a certain minimum quantity is delivered. If you succeed to deliver a better quality and partly this even in more quantity, you receive additional funding. This motivates to invest for example in better communication and awareness programs for your inhabitants respective to monitor and control what the inhabitants put in the bags. In some countries, the collecting bags are therefore transparent so that the collector can easily see whether the right material in included and if not, reject the bag.
 
JC: In Canada, in the provinces where producers provide partial funding for the recycling system, producers (or their agencies) are not in a position to influence the delivery of the recycling system or the quality of the materials collected.  Rather, stewards reimburse municipalities for a portion of the cost incurred to provide residential recycling services - the type of service provided is determined by the local government. In this system of shared financial responsibility, both stewards and municipalities share in the benefits of reduced contamination levels (lower cost) and cleaner streams of marketed materials (higher revenues). Although, as we've recently experienced, the restrictions imposed by China have significantly impacted revenues.
 
4. A national framework will only work if governments make a real, time-bound commitment to implement it. For example, the CCME's EPR commitment, which all provinces committed to in 2010, was not implemented across Canada (most notably Alberta). What would be different about the national framework you've suggested and what would you see as the lever to make a national framework more than another feel good dust-collecting document?
JC: Circumstances are greatly altered since 2009 when the CCME committed to the Canada-wide Action Plan for Extended Producer Responsibility. The current global plastics crisis has focused attention and energized governments to act to reduce plastic waste; the drive to create circular economies for materials has gained significant momentum over the past 18 months; and the China ban on recyclables is having a significant impact on the ability for municipalities and stewardship organizations to market their recyclables. The Canadian government has taken the lead on the Ocean Plastics Charter and followed up with a consultation with Canadians on a Framework for Zero Plastic Waste. We see these actions as a strong signal that the Canadian federal government, in conjunction with the Provinces, can address all such wastes and we are optimistic that a coordinated national framework for extended Producer Responsibility can be a component of that strategy. 
Also in the interim, many organizations, including Unilever have set ambitious targets to switch to 100% recyclable packaging by 2025 and to include increasing higher levels of recycled content in their packaging and products. Full producer responsibility is critical to achieving these goals as a means of addressing plastic pollution and in this both government and producer objectives are aligned as never before.
 
5. Full responsibility? What does that entail? What do you mean by Shared Responsibility? 
JQ: This can mean different things: You can have full responsibility cost wise and / or full responsibility on the operations. For example: 
• Belgium has a full cost responsibility system for household packaging (costs for collection, sorting, recycling, communication) but the operational responsibility is shared between municipalities and the EPR system. Municipalities have the responsibility to organize the collection and sorting, the EPR system organizes the marketing of the sorted materials.
• In Germany, the EPR system is fully responsible operationally to organize the collection, sorting and recycling and bears (logically) the full costs for it.
• In Slovenia, the municipalities are operationally and cost wise responsible for the collection and the EPR system is then responsible for sorting and recycling (operationally and cost wise)
• In the Netherlands, the municipalities are fully operationally responsible for collection, sorting and recycling and the EPR system has the full cost responsibility to sponsor these activities (if strict criteria on quantity and quality are fulfilled).
So, you always have to ask for the exact details of an approach. What is best for your country depends on many factors, especially for example how structured, organized and professional the municipalities are acting in general.
  
JC: Full producer responsibility refers to a system which is financed and operated by producers - the organizations (e.g., brand owners and retailers that supply packaging and paper product in the marketplace.  In Canada, full producer responsibility for packaging and paper product exists only in the province of British Columbia. In that province, Recycle BC (the stewardship agency which acts on behalf of stewards) contracts with local governments and the waste management industry to deliver collection and processing services on behalf of its members.  Shared Responsibility systems are in place in four other provinces in Canada (Quebec, Ontario, Manitoba and Saskatchewan) where stewards reimburse local governments either a portion or the full amount of the costs they incur for the delivery of recycling services to their residents under an approved program plan.  With shared responsibility, producers have very limited or no control over the delivery of the services to residents. As a result, producers cannot influence system design to include more types of packaging, standardize the items collected in all municipalities, create common promotion and education materials, and otherwise improve system-wide efficiencies, cost controls and performance outcomes.
 
We know that municipalities are doing their best and have built up best practices within the limits of each of their jurisdictions.  However it is well understood that the fragmentation resulting across municipal borders is a significant barrier to the achievement of economic and environmental objectives.
 
6. The new Circular Economy package brings increased targets and a more strict view from the EU on moving up the waste hierarchy. How can EU (pre)accession countries (e.g. Western Balkan, Caucasus region) meet these targets when they start literally from scratch?
JQ: They can do it as they are getting a lot of funding, they can benefit from all the experiences and know how of the "old" member states and they get more time to reach the targets. The bigger problems are on the social side as they are having partly a strong informal sector that lives from waste collection respective from sorting out of landfills. Only long term approaches by helping their kids to go to school and getting a good education can finally solve this challenge.
 
7. Is the loss of efficiency of single-stream recycling (compared to source separated recyclables) worth the increased participation rates?  Consider short term versus long term achievement of circular objectives.
JQ: Why loss of efficiency? Before starting separate collection in my home town Bonn, the waste was collected every week. Now the waste is also collected every week but in week A the plastics and metals, in week B the paper, week C bio waste and in week D the remaining residual waste. So, I do not see a loss in efficiency of the collective system. 
 
Moreover sorting the waste makes people understand what they are really producing. It makes you aware and you start to think.
 
JC: There are many viewpoints on this, a much-debated subject over the years. The merits of single-stream collection, typically in carts that are automatically or semi-automatically collected, are many. This form of collection tends to increase participation rates due to resident convenience. It can also have significantly reduced collection costs, speeding up the time spent per household and reducing the number of trucks on the road. Fewer trucks results in reduced greenhouse gases. These benefits, combined with reduced workplace injuries and a shortage of drivers has led many communities to adopt single-stream collection systems. 
 
However, there are also some disadvantages to single-stream collection namely: a requirement for greater investments in sorting facilities and technologies to separate fibers from containers; typically, the contamination rates are much higher than multi-stream (or source separated) collection and this can add cost to the sorting process and reduce revenues earned in the sale of the recyclables. Additionally, as allowable contamination thresholds become increasingly stringent for marketed commodities it can become even more challenging to find end markets for single-stream materials.
 
Multi-stream collection requires a greater investment up-front, both by the resident and the collector. This comes with a cost, be it financial and/or through reduced participation. These programs however, tend to have better access to end markets and command higher prices due to lower contamination levels.
 
There are tradeoffs that must be considered for both systems but at this time it is important to improve overall recovery performance in a move to a system-wide transition while we study further on how to then optimize certain operational practices. Developments will continue to be debated as new technologies and investments evolve - in some cases rapidly with the benefit of greater scale.
 
8.  Can you comment on the best approaches to dealing with single use plastic bags and newspapers?
JC: Both single-use plastic bags and newspapers are included in the Packaging and Paper Product EPR programs in Canada - both the full producer responsibility and the shared responsibility programs.  Stewards pay fees on these materials reflective of the cost to manage these materials in the recycling system.  In the shared responsibility jurisdictions, local governments make the decisions on whether or not they will collect these materials from residents and how they will be collected. This varies from province to province and from community to community.  In British Columbia, where stewards finance and operate the recycling system, plastic bags are collected through depot collection and newspapers are collected at curbside (for those who receive curbside service), through multi-family building collection and at depots.
 
9. Where can we find the video content to check out for the national campaign on sorting waste?
   
10. Any views on 3rd party auditing of non-financial performance indicators? This helps to standardize reporting and increases accountability. But it can be expensive to carry out annually so a cost-effective mechanism has to be worked out...any views?
JC: In a full producer responsibility jurisdiction, the stewardship agency is able to engage an independent party to review its non-financial performance. For instance, in British Columbia, each load of material collected in the PPP program is recorded, reviewed, verified and approved by Recycle BC. This is followed by an assurance audit conducted by an independent, third-party auditor who verifies the data used to calculate the reported recovery rate by Recycle BC. In addition, third party assurance audits are conducted on other performance metrics that are required by the government and in the interest of transparency, all findings of the third-party assurance audits are included in the Recycle BC Annual Report.
 
11. How are eco-design practices considered in the eco-modulation of fees?
JC: Canadian Stewardship Services Alliance Inc. (CSSA) has developed a fee methodology referred to as the Four Step Fee Methodology which is used to set stewardship fees for packaging and paper products programs in British Columbia, Saskatchewan and Manitoba, and we expect, eventually it will be adopted for use in Ontario, as well. A link to the methodology and how it works is available here.
  
The fee methodology does have the effect of rewarding recyclable materials and ensuring that non-recyclable or difficult to recycle materials are not inadvertently rewarded. There are a number of ways in which the methodology does this:
• There is no sharing of commodity revenue. Only materials that are collected in the recycling system and subsequently sold to recycling end markets are allocated a share of the revenue to help offset the cost to manage their materials. 
• All materials assume their relative share of 60% of the gross cost of the recycling system whether or not they are collected. Most importantly, this relative share is calculated using both the quantities of material sold and the material's cost per tonne to manage. As such all materials are assuming the 60% of gross costs as though they were managed in the recycling system. In this way, materials that are not collected and recycled are assuming a share of the gross costs and this necessarily reduces the share being attributed to those materials that are actually collected and recycled. 
• Finally, Step 4 of the methodology attributes cost to those materials that require investment to improve their cost and performance effectiveness in the recycling system or are needing recycling end markets developed so they can move from a material that is only disposable, to one that is recyclable. 
These elements of the fee methodology are designed to reward recyclable materials and encourage a design-for-recycling mindset amongst producers.
  
12. How do you harmonize nationally or even globally? What org's should be involved in this?
JQ: For me the current top priority would be to harmonize the approach to have everywhere a functioning collection system to avoid that further waste is entering the environment and the oceans.
 
From an internal EPR point of view, we should probably seek more harmonization which data and info each of the systems is asking from its clients. I think that agreeing on a certain set of data that we all ask from industry would save a lot of additional costs.
 
We should also develop and agree on standards for the sorted materials and their minimum quality. Like for paper, where there are a set of global standards. This would for sure ease the marketing of the sorted materials, ensure that recyclers know what exact quality they buy etc. We are working on this with CEN but this takes of course some time.
  
JC: National harmonization in Canada could take the form of framework legislation developed by the federal government in partnership with provinces to harmonize definitions and performance standards across provincial stewardship programs. Producers would benefit from the adoption of a harmonized approach to the definition of obligated parties, definition of designated materials, performance measures, reporting requirements and other elements of the stewardship programs. 
 
 At a global level, the Ellen MacArthur Foundation's New Plastics Economy is a leader in accelerating global action across business, governments, civil society and academic institutions to address the current plastic waste crisis. The recently released Global Commitment takes this work to the next level - creating a global coalition of leaders with the power to prevent plastic pollution at the source. This new commitment not only requires the reporting of progress by those organizations that have made commitments to reduce their plastic waste, but also provides much-needed common definitions to assist in harmonizing reporting and measuring performance across jurisdictions for terms such as: Reusable packaging, Reuse, Recyclable packaging, Recycling, Compostable packaging, Composting, Post-consumer recycled content, and renewable material. The adoption of common definitions of these terms will enable greater international collaboration across parties for the achievement of shared goals.
 
13. What are the top 3 system aspects that you would consider Best Practices to achieve the best results?
JQ: 
1. Clear legislation describing the roles & responsibilities of each stakeholder with a functioning enforcement by the government
2. A single service provider owned and run by the obliged industry who is pro-active, pushing, listening and innovative 
3. A creative and constant communication and awareness program to our inhabitants and especially to the pupils combined with a "packaging & sustainability" program for obliged industry 
JC: The key elements of a best-in-class EPR system would be: 
• Full producer responsibility where producers have both financial and operational responsibility (and accountability) for the packaging and paper product recycling system and are thereby able to ensure consistent and easy access to recycling services for residents, fair and reasonable cost management, performance standards and contract terms and responsibility for performance outcomes;
• Harmonized regulations across jurisdictions with a common set of definitions for obligated parties, designated materials, performance measures and reporting requirements;
• Full engagement of regulators to provide a level playing field through effective compliance and enforcement measures, and to identify effective mechanisms to legally obligate producers of e-commerce packaging and products. 
   
14. With respect to on-the-go or out of home packaging, what is the best collection method for its recycling and what are the levels of contamination?
JQ: I do not think that there is any best collection method for out of home packaging. The most important thing is to have an infrastructure for this, to have enough bins and/or an appropriate emptying rhythm.This has to be combined with clear and straight communication and awareness program but supported by enforcement. If it is socially accepted to litter, how can you expect the people to take the extra meter to sort? See Singapore, if you litter you get caught and punished. And people know by heart, that they will be seen. So, there is really no litter on the streets. Of course, this might be a bit too strict for our western societies but seeing people littering their cigarette butts in front of the police without reaction is not acceptable.
 
JC: Our understanding of the challenges in delivering effective public space recycling is best informed by the work undertaken on streetscape recycling by Recycle BC. Recycle BC has worked with local governments over the past several years on a number of pilot projects to examine different consumer communication methods and different collection bins for effective public space recycling. To date, the results of the pilot projects continue to show a high level of contamination in streetscape material but Recycle BC will continue to work in partnership with local governments to conduct additional streetscape collection studies to determine how to best reduce the contamination levels such that streetscape material can meet marketability criteria.

 

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